Tweet
I have been trying to get a field approval for the Grove wheel and brake conversion here in Montana but am having no luck. What is involved in having this done in another state? Is residency an issue? Can I just fly the plane to another location, have the field approval and work completed there, and then fly home and be happy? Going to Alaska is not an option since Canada will not let me fly through their airspace without a medical, so I am limited to the lower 48. Has anyone else done this?
-
-
Re: Field Approvals?
As I am sure you are aware, approvals are based on data. If you are dealing with your "local" office and they are stonewalling you, I would suggest you contact the Denver ACO (Aircraft Certification Office) about a "one time" STC. Before you do that, gather as much data as you can. There is a formula for computing the brake energy required to stop the aircraft at a certain weight and speed. I am sure Grove can supply you with the brake energy capability of the brakes you are planning to use. One of the most limiting factors involved is the shear strength of the bolts used to attach the torque plate to the landing gear. You can contact the bolt supplier for the shear strength of the bolts you are planning to use. Spend a few hundred dollars to hire a DER to show you how to present all of this to the ACO. Once you fill out the form to apply for a one time STC, they will assign an engineer to let you know what sort of testing might be required. I would give the certification regs a good look see before applying. You want as much info as you can get in hand before you apply. Once you document how you plan to comply with each segment of the CARs that deal with brakes for your airplane, you should be well on your way to approval.
While this may sound like a lot of trouble and expense, it at least provides a definite path to approval. Hopscotching around the country to find a local FAA office sympathetic to your needs might end up taking a lot longer and costing more. Maybe someone will offer up a suggestion for a local FAA office that is sympathetic to those seeking field approvals, but I haven't heard of one.
Denver ACO
Technical Operations Center (TOC)
26805 East 68th Avenue, Room 214
Denver, CO 80249
PH: (303) 342-1080
FAX: (303) 342-1088 Colorado
Montana (eastern portions)
Utah
WyomingRichard Pearson
N43381
Fort Worth, Texas -
Re: Field Approvals?
Ask the faa to provide a coordinated field approval or find the data where it was done exactly as before. Its REQUIRED by REGULATION and funding that they must do field approvals. TimN29787
'41 BC12-65Comment
-
Re: Field Approvals?
Which REGULATION (FAR) REQUIRES Airworthiness Inspectors to do field approvals. I was an A/W Inspector for 20 years, but I guess I missed that regulation.Originally posted by astjp2 View PostComment
-
Re: Field Approvals?
Ok, I jumped the gun on that one, it used to stated in 8900-1 but new guidance in afs300 still allows for them. http://www.faa.gov/about/office_org/...on_Job-Aid.pdfN29787
'41 BC12-65Comment
-
Re: Field Approvals?
E Changes to Systems that Affect Aircraft Airworthiness, Such as:
1 Changes to landing gear and related components, such as internal
parts of shock struts, length, geometry of members, brake and
brake systems, or additions.
EVLN29787
'41 BC12-65Comment
-
Re: Field Approvals?
My mechanic submitted a proposed 337 form based on the previously approved 337 for the Grove wheel and brake conversion that is posted on our Taylorcraft Foundation website. There are many photos there that show exactly how this is done, so I don't really understand why the Montana FSDO does not want to approve this.Comment
-
Re: Field Approvals?
Montana T,
Pictures are great for showing how the verbage in a 337 or STC explains how something is done. But it is the verbage that explains how the modification complies with the CARs or FARS that the aircraft was certified under. Obviously drawings can show details that would be complicated to describe in a written form. If you explain how your modification meets or exceeds the regs, and show that it uses approved methods as in AC43.13, there is no reason for them to deny the mod. Ask them what data they need. PM me. I will be glad to help.Richard Pearson
N43381
Fort Worth, TexasComment
-
Re: Field Approvals?
As has been stated many times before.... 337's after a certain date (I can't pull the exact date off the top of my head) may be used for acceptable data... they aren't approved data. Just because it got done once, doesn't mean it will again. The FAA inspector doesn't have to sign off on any field approval if they aren't comfortable with it, for whatever reason. I'm not saying that's a good thing, but nothing says they have to. I'd talk to the inspector and see what they say as far as why they're reluctant to sign off. If they're not sure of what they're reading, they may want an engineer to look it over and give them approved data, then it will go through. It may be the way it's presented by your mechanic, or the relationship, or lack there of, that your mechanic has with the inspector. I'd call the FSDO and speak with the inspector myself and see what his thoughts are. I know it's mostly a "newer" bunch in there and things have tightened up in the last 20 or so years, but I've still always had good luck with them, and a little phone call can go a long ways sometimes, in understanding what's going on.
JohnI'm so far behind, I think I'm aheadComment
-
Re: Field Approvals?
Richard,
I think what you are telling me is that my mechanic has not done a very good job of presenting this to the FSDO.Comment
-
Re: Field Approvals?
I wouldn't say that your mechanic didn't do a very good job. It might be a case of just giving up too easily. John is spot on in his post above. This sounds like a lack of communication. I agree with John that you should contact the person responsible for declining the approval and ask them what info they need to approve the modification. I have found that it is critical to refer to the regs the plane is certified under when applying for mods. The burden in on YOU, or your agent (DER, I/A, etc), to show how your mod complies with those regs. The FAA person is not going to thumb through the regs for you. I know your original question addressed dealing with a different FAA office. But I don't know if you can do that. It really isn't all that complicated to write out how a brake installation meets or exceeds the regulatory requirements these old planes are certified under. But you have to do the leg work for the FAA person. Why not give Terry Bowden a call and ask him for an estimate on what his services would cost to work with you to get this approved. Or you might possibly ask him to contact the FAA on your behalf. I mentioned submitting an application for a one time STC to the Denver ACO because then you would be dealing with an engineer instead of the regulatory types at the FSDO.Richard Pearson
N43381
Fort Worth, TexasComment
-
Re: Field Approvals?
Field approvals prior to Oct. 1955 can be used as approved data. After that date F.A.'s can only be used as a basis for approval. As far as Inspectors go, we (inspectors) all had experience in different areas/disciplines. For example, I wouldn't hardly touch a F.A. on a pressurized, gas turbine powered airplane or a helicopter because my prior experience was very thin to non existent with those type aircraft. One the other hand, the Inspectors with Turbine powered heavies wouldn't touch a one of our Maytag Messerschmits. It was just an experience/background thing and I think our 8300 sries orders addressed that issue.Originally posted by N96337 View PostComment
-
Re: Field Approvals?
Did you print and send all of my field approval that is in the teck section . as there is also two older 337 in there that were done in alaska. the nashville FSDO did it for me. also check 23-27 advisory circular here is a guide to how to do this. two other people have don it this way with out any FSDO involvment .1940 BLT/BC65 N26658 SER#2000Comment
-
Re: Field Approvals?
Charles,
Yes, all of your material was submitted with the proposed 337 for my plane. I was unable to read the attachment that you sent. It was just too blurry. Is there any chance that you could send it to me in a different format or tell me where I can access it at another site? ([email protected]) Thanks for your help.
CharlesComment
-
Re: Field Approvals?
Charles, here's the link to AC-23-27 that Chuck Avon references above. http://rgl.faa.gov/REGULATORY_AND_GUIDANCE_LIBRARY/RGADVISORYCIRCULAR.NSF/0/ccf7daac581048cd862575e6006ca078/$FILE/AC%2023-27.pdf
JohnI'm so far behind, I think I'm aheadComment
Comment